ML23334A237

(Vvsns), Unit 1 - Annual Commitment Change Summary Report

ML23334A237
Person / Time
Site:	Summer
Issue date:	11/30/2023
From:	Ryan Justice Dominion Energy South Carolina
To:	Office of Nuclear Reactor Regulation, Document Control Desk
References
23-315
Download: ML23334A237 (1)

Text

V.C . Summer Nuclear Station Bradham Bl vd & Hwy 215 , Jenkinsville, SC 29065 Mailing Address:

!51; Dominion

~ Energy P.O. Box 88, Jenkinsvi ll e, SC 29065 Do minion En ergy.com November 30, 2023 Document Control Desk Serial No.23-315 U.S. Nuclear Regulatory Commission VCS UC/HK/Rev 0 Washington, DC 20555 Docket No. 50-395 License No. NPF-12 DOMINION ENERGY SOUTH CAROLINA (DESC)

VIRGIL C. SUMMER NUCLEAR STATION (VCSNS) UNIT 1 ANNUAL COMMITMENT CHANGE

SUMMARY

REPORT Dominion Energy South Carolina hereby submits the 2022 Annual Commitment Change Summary Report. The commitment change was performed in accordance with VCSNS Regulatory Commitment Management Program , which was developed following guidance from NEI 99-04 "Guidelines for Managing NRC Commitment Changes."

Should you have any questions, please contact Mr. Michael Moore at (803) 345-4752.

Sincerely, stice Site Vice Presiden V.C. Summer Nuclear Station

Attachment:

Summary of Commitment Changes cc: G. J. Lindamood - Santee Cooper L. Dudes - NRC Region II G. Miller - NRC Project Mgr.

NRC Resident Inspector

Serial No.23-315 Attachment Page 1 of 2 VIRGIL C. SUMMER NUCLEAR STATION (VCSNS) Unit 1 DOCKET NO. 50-395 OPERATING LICENSE NO. NPF-12 ATTACHMENT

SUMMARY

OF COMMITMENT CHANGES

Serial No.23-315 Attachment Page 2 of 2 The following commitment change, with a brief justification, was performed during 2022 in accordance with the Dominion Energy South Carolina (DESC) Regulatory Commitment Management Program, which was developed following NEI 99-04, "Guidelines for Managing NRC Commitment Changes." The changes are documented in the station's corrective action program condition reports (CRs):

CR-21-02651 Original Commitment Summary - NRC Request for Additional Information 4.3.2-1 (ML030900096), requested additional information concerning ASME Section Ill, Class 2 and 3 piping fatigue, specifically concerning the post-accident and nuclear sampling system potentially approaching the 7,000 cycle limit during the period of extended operation.

VCSNS's response to RAI 4.3.2-1 (ML031681125) states, in part:

"The present sampling method seldom uses loop sampling. VCSNS will administratively limit the use of this loop for emergencies only, for an average of no more than once per cycle. In so doing, the 7,000 cycle limit will not be reached during the period of extended operation. Should sampling methods change such that this loop would be required for more frequent sampling, either a detailed stress analysis would be required that increases the cycle limit to an acceptable limit or the affected components would be replaced."

Change - "The present sampling method seldom uses loop sampling. VCSNS will administratively limit the use of this loop for emergencies and the performance of the integrated leakage assessment test. In so doing, the 7,000 cycle limit will not be reached during the period of extended operation. Should sampling methods change such that this loop would be required for more frequent sampling, either a detailed stress analysis would be required that increases the cycle limit to an acceptable limit or the affected components would be replaced."

Justification for Change - The operation of the 'B' RCS loop sampling line is required once a cycle with the plant in Modes 1 through 3 to allow for the performance of STP-250.024, Nuclear Sampling System Leakage Assessment Test, as required by Technical Specification 6.8.4.a, Primary Coolant Sources Outside Containment.

This surveillance test is not considered an emergency situation or a routine sampling activity as described in the original commitment. Therefore, a commitment change was needed to allow for the surveillance test to be performed while still ensuring that the 7,000 cycle limit for thermal fatigue imposed by ANSI 831.1, Power Piping Code, is maintained without impacting the validity of VCSNS' election to utilize 10 CFR 54.21(c)(1)- Option (i) for the ASME Section Ill Class 2 and 3 Piping Fatigue Time-Limited Aging Analyses in section 4.3.2 of the License Renewal Application.